Transfer Pricing

Multinational organizations are operating in an environment of unprecedented complexity. The rising volume and variety of intercompany transactions and transfer pricing regulations, accompanied by increased enforcement activities worldwide have made transfer pricing a leading risk management issue for global businesses. The goal of Deloitte’s transfer pricing network is to help companies manage risks by aligning practical transfer pricing solutions with their overall global business operations and objectives, assist with strategic documentation to support their transfer pricing practices, and resolve disputes efficiently. Deloitte has a well-earned reputation for quality and delivering results.

Explore content

Navigating a new transfer pricing environment

The OECD’s BEPS project has proposed various updates to the OECD Transfer Pricing Guidelines through the final reports on BEPS Actions 8-10. This new guidance has been hailed as a game changer expected to alter the transfer pricing outcomes in many situations and to require multinational enterprises to undertake additional analysis and documentation.

But how will the new guidance impact your company?

In this book, the transfer pricing professionals of Deloitte have sought to provide practical considerations in answer to that question. The nine articles in this collection each address a specific transfer pricing issue, providing an overview of the changes wrought by the new guidance and practical recommendations for taxpayers who will find themselves navigating the new transfer pricing environment. The articles are presented in the same order as the topics they address appear in the final OECD reports.

Transfer pricing advisory and documentation

Multinational businesses are expanding the volume of related-party transactions and continuously improving their supply chains. This coupled with increased tax authority collaboration across borders presents both risks and opportunities. Deloitte provides practical solutions such as strategic approaches to transfer pricing documentation requirements, which help global businesses to achieve their operational and international tax objectives.

Deloitte has a Global Transfer Pricing Center, that includes economists, tax professionals and MBAs who have on-the-ground international transfer pricing experience in Europe, the Americas or the Asia Pacific regions. This centralized global approach facilitates uniformity of reporting and eliminates internal inconsistencies which can arise from multiple service providers, thereby making the process more effective, efficient and easier to explain to the relevant authorities.

To deliver transfer pricing documentation services Deloitte has a Global Dox Insight methodology. This is powered by TP Search Smart technology, streamlining the gathering and processing of data and information needed to make informed business decisions.

Dispute avoidance: Advance pricing agreements

Transfer pricing presents many tax, legal and operational challenges. To many taxpayers the magnitude of uncertainties – including the potential commitment of significant management time in the event of a transfer pricing examination – is not an acceptable business risk. Advance pricing agreements (APAs) allow taxpayers to achieve greater certainty via advance agreements on their transfer pricing methods with one or more tax authorities. Deloitte's experience with the APA process spans the development of the national programs and this historical knowledge and insight combined with more recent practical experience helps us help companies to manage their transfer pricing issues – particularly the risk of double taxation – on a prospective basis.

Often it is the actions and responses in the initial stages of a tax authority enquiries or interviews that affect the course or outcome of a transfer pricing examination. Accordingly effective and efficient explanation of a business transfer pricing policies include early involvement of an experienced global team that has practical experience of all levels of the tax authority process, from proposed adjustments by field agents, through Advance Pricing Agreements, administrative appeals, litigation and the MAP process. Deloitte takes an integrated approach to resolving transfer pricing disputes in the MAP process. Our teams include transfer pricing MAP specialists from both countries in dispute teamed with professionals who specialize in local country requirements for indirect taxes, taxes imposed by local or state/provincial jurisdictions, international tax and interest calculations for late payment that invariably affect the outcome.

Business model optimization

The global economic environment is characterized by continuous improvements in technology, an urgency to adopt and implement best practices and processes, and the potential for legislative change. Assessing a multinational's global business model is no longer an optional exercise. Business Model Optimization (BMO) is the process of understanding the demands of operations and of tax law and integrating them into the business model. Deloitte provides high quality, customized tax and BMO services that focus on helping multinationals integrate operational and tax requirements in a scalable and sustainable way in order to help business leaders to make effective decisions on an after-tax basis.

Deloitte delivers business model optimization services using the BMO Insight methodology, a set of experience based approaches to developing solutions to a range of tax issues and opportunities.

Get In Touch

Regional Managing Partner, SEA Tax and Legal

Mr Low Hwee Chua, Deloitte Singapore, is a tax partner and has more than 25 years of experience in taxation services including two years with the Inland Revenue Authority of Singapore. He is the regio... More

Deloitte refers to one or more of Deloitte Touche Tohmatsu Limited (“DTTL”), its global network of member firms, and their related entities. DTTL (also referred to as “Deloitte Global”) and each of its member firms are legally separate and independent entities. DTTL does not provide services to clients. Please see www.deloitte.com/about to learn more.